Privacy Policy | PassbookMax

This privacy policy ("Policy") explains our policy regarding the collection, use, disclosure and transfer of your information by ADJ Utility Apps Private Limited or any of its affiliate(s) ("we" or "us" or "our"), which operates the "PassbookMax" application (the "App") available on Google Play Store and other similar platforms and other services including but not limited to viewing bank transactions and balances via the App, any mobile or internet connected device or otherwise (collectively the "PassbookMax App Service"). This Policy forms part and parcel of the Terms and Conditions of Use for the PassbookMax App Services. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms and Conditions of Use. Users (as defined hereinafter) are requested to read this Policy in conjunction with the Terms and Conditions of Use.

The App provides a read-only digital passbook that allows Users to view their bank account transactions and balances from multiple banks in one place, using data fetched via RBI-licensed Account Aggregators ("AA") (collectively, "Services"). Please note that 'Services' would include any other future services we may provide or propose to provide.

As we update, improve and expand the PassbookMax App Service, this Policy may change, so please refer back to it periodically. By accessing the App or otherwise using the PassbookMax App Services, you consent to the collection, storage and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

We respect the privacy of the users of the PassbookMax App Services ("Users" or "you") and are committed to reasonably protecting it in all respects. The information about the User as collected by us is: (a) information supplied by Users and (b) information automatically tracked while using a mobile device having the PassbookMax App Services enabled (collectively referred to as "Information"). By using PassbookMax App Services, you agree to this Policy. If you do not agree with any term in this Policy, please do not use or avail of the PassbookMax App Services.

Information Supplied by Users

To avail certain Services on the PassbookMax App, Users are required to provide certain personal information for the registration process which may include:

• Name, phone number and user id.
• Device or other IDs — identifiers that relate to an individual device or app instance.
• Crash and Diagnosis — We collect crash log data and information about the performance of the App for technical diagnosis purposes.
• App interactions — Information about how the User interacts with the App, for example, the number of times they visit a section or features they tap on.
• We collect information if you raise a query or contact us through phone or email for support purposes.
• We use tracking tools such as Google Analytics and crash diagnostics tools to collect information about your usage of the App.

The Information as supplied by Users enables us to provide the Services, improve the PassbookMax App Services and provide the most user friendly experience. All Information is service dependent and we may use the Information to provide the Services, maintain, protect and improve the PassbookMax App Services and for developing new services.

We may use your phone number to contact you for transactional, administrative and service related purposes (such as notifying you of major changes, customer service, updates to PassbookMax App Services and billing). For marketing communications, we will contact you only where you have provided consent or where permitted under applicable law.

Any Information provided by you will not be considered as personal information if it is freely available and/or accessible in the public domain or is not deemed as personal information under applicable law.

In case you choose to decline to submit Information on the PassbookMax App, we may not be able to provide certain services on the App to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and/or responsible for the denial of certain services to you due to not receiving necessary Information from you.

Bank Account Data via Account Aggregator

PassbookMax fetches your bank account data (transaction history and balances) exclusively through RBI-licensed Account Aggregators (AA) operating under the RBI Account Aggregator Master Direction, 2016 (as amended). This process works as follows:

• You provide explicit, OTP-based consent through the AA framework to authorise data fetching from your bank accounts.
• No net banking credentials, passwords or PINs are ever collected or stored by us at any point.
• The App is strictly read-only. No money transfer, payment initiation or financial transaction of any kind is possible through the App.
• Data is fetched only with your explicit, informed and revocable consent as required under the AA framework.
• Fetched transaction and balance data are stored on secure cloud based servers solely to display it within the App and is retained only for as long as necessary to provide the Services or as required by applicable law.

Information Automatically Tracked While Using the App

Log File Information: Our servers automatically collect limited information about your device's connection to the internet, including your IP address, when you use the App. We automatically receive and log information from the App including but not limited to IP address, your device name and your operating system. We may also collect log information from your device including your device name, unique device identification number, operating system, browser type and version and connection speed.

Analytics: We may use analytics tools to understand usage patterns within the App in order to improve our Services. This data is collected and analyzed on an aggregated basis and is not used to personally identify individual Users.

Link to Third Party Sites

The App may include links to other websites or services. Such websites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting and we make no representation or warranty on how your information is stored or used on third-party servers.

Information Sharing

The Information (including personal information) collected may be shared with our affiliates and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and to any third party service providers, and the User hereby consents to the same.

We will take reasonable steps to ensure that these third-party service providers are obligated to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and comply with the applicable provisions of data protection laws.

Further, the User also consents to sharing of Information when it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offenses. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing the Terms and Conditions of Use or for complying with applicable laws and regulations.

No personal information of an individual User such as name or phone number would be shared with any other User and/or third party unless explicitly approved by the concerned individual User.

We share crash logs and diagnostics data with the Play Store to improve the user experience.

Please note that the data sharing described in this Policy is limited to service providers acting on our behalf under appropriate data processing agreements. We do not sell your personal information to third parties.

Accessing and Updating Personal Information

When Users use the App, we make good faith efforts to provide Users, as and when requested, with access to their Information and shall further ensure that any personal information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such information to be retained by law or for legitimate business purposes.

Under applicable data protection laws, you have the right to access, correct and request deletion of your personal information held by us. To exercise any of these rights, please contact us at utilitylabs002@gmail.com. We will respond to such requests within a reasonable time and in accordance with applicable law. We may ask you to verify your identity before processing your request.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or are otherwise impractical.

Information Storage and Backup

From time to time, we take backups of your data on our cloud database. This is done for the purpose of enabling Users to get their data back in case their mobile's data becomes unusable, or mobile gets lost, or the User moves to a new mobile device and to provide useful insights related to their transaction history. We also use this backup to provide information related to User transaction patterns in the form of aggregated and anonymised statistics.

We shall retain User Information for as long as the User's account is active or as needed to provide the Services and for such additional period as may be required under applicable law. Upon deletion of your account or upon your request for deletion (where no legal retention obligation exists), we will take reasonable steps to delete your personal information from our active systems. Residual copies in backup systems may take additional time to be purged.

Information Security

We take appropriate security measures to protect against unauthorized access to or alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All Information gathered on the PassbookMax App is securely stored within a controlled database. Access to the servers is password-protected and strictly limited.

Our security measures are regularly reviewed and updated to reflect technological developments. However, please understand that no transmission of data over the internet or any other public network can be guaranteed to be 100% secure.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable law and without unreasonable delay.

Revocation of Consent

A User can revoke consent to the processing of personal information at any time with effect for the future. Consent for bank data fetching via Account Aggregator can be revoked through the AA framework. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal information where such collection, use and disclosure without consent is permitted or required under applicable laws. Revocation of consent may result in the inability to use certain features of the App.

Responsible Organisation for Data Collection

All the PassbookMax App Services are currently provided and regulated by ADJ Utility Apps Private Limited and therefore ADJ Utility Apps Private Limited is responsible for the collection, storage and processing of personal information of the Users.

Purpose of Data Processing

We will only collect and process Personal Information about you where we have a lawful basis to do so. Our primary purpose in collecting your information is to deliver the personalised PassbookMax Application and its various features. Should you choose not to provide consent for the collection of your information, you may not be able to access certain features of the App or we may not be able to provide the PassbookMax App Service in entirety.

We use your Personal Information for the following purposes:

• To register you on the Application and create your account.
• To provide you with customer or technical support, including addressing queries related to bank account linking, subscription processing and diagnosis of technical problems.
• To send you transactional SMS or other communications regarding your account, subscription or the Services.
• To send you information about promotions, offers, new features or products of the Company or its affiliated entities, where you have provided consent or where permitted under applicable law.
• To prevent, detect and investigate potentially prohibited or illegal activities, including fraud and to enforce our Terms.
• To notify you about changes in the Terms and Conditions of Use or in this Privacy Policy.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To comply with applicable legal and regulatory obligations.

Updates / Changes

We may alter our Policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change the terms of this Policy or the Terms and Conditions of Use at any point of time. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the App. Your continued use of the PassbookMax App Services after such notice will be deemed acceptance of such changes. You are advised to review this Policy periodically to ensure that you are aware of the latest version.

Questions / Grievance Redressal

In the event you have any grievance relating to the processing of Information provided by you, you may contact our Grievance Officer at utilitylabs002@gmail.com. We will endeavour to acknowledge your grievance within 48 hours and resolve it within 30 days of receipt, or as required under applicable law.

You may also write to us at:

Grievance Officer
ADJ Utility Apps Private Limited
1539, 18th Cross Rd, Sector 3,
HSR Layout, Bengaluru,
Karnataka - 560102

Disclaimer

In case any personal information is shared by you with us which is not requested by us during registration (whether mandatory or optional), we will not be liable for any information security breach or disclosure in relation to such information. If you have any questions regarding this Policy or the protection of your personal information, please contact our Grievance Officer at utilitylabs002@gmail.com.